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ICAC Met with the White House Office of Management and Budget

ICAC in conjunction with the Partnership for a Better Energy Future, Council on Environmental Quality and EPA met on Monday, June 8th with the White House Office of Management and Budget to discuss the Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources based on our comments filed in May of 2014 - view the comments here. ICAC emphasized some overarching issues with respect to the new unit GHG NSPS:

Adequately demonstrated – it is difficult to agree on a threshold for what constitutes “adequate demonstration” of the commercial viability of CCS. Such a demonstration should include supply chain issues and long term operation.

Safe landing – traditionally, this has meant that costs to the owner should be covered by the Government for a period of time prior to proving the operation at full scale.

Capture level – these are existing plants so a retrofit would be required, there are too many factors that may make retrofits at existing sites impractical; a minimum level might be based on how much CO2 you could sell that did not require a pipeline and underground storage, but again site specific; there may be no generic capture level that is practical

Heat rate – these are existing plants, it seems impractical to set a heat rate that could be fairly applied to all coal plants (steam cycle, coal, altitude, age, etc); other than minor efficiency improvements there is no way to reduce the CO2 from a coal plant; anything else requires a fuel change or a capture system